Category: Interesting publications & events

The ONR has recently agreed to a major revision of the Magnox Limit’s emergency plans. In a Project Assessment Report available on the internet they approve the removal of the Central Emergency Support Centre (CESC) from the Magnox emergency plans.

The CESC is a large control room in EDF’s headquarters in Barnwood. It provides for the off-site support for a nuclear power station in an emergency situation. Command, technical, health physics and support teams are available at short notice during working hours and within an hour or so out of hours. The technical team helps to understand the situation on the site and provide advice on how to rectify the situation and on the release prognosis. The health physics team takes over the off-site survey and combines the knowledge gained about off-site doses with the predictions of the changing situation from the technical team to provide estimates of the public avertable dose to support the countermeasure decision process in the Strategic Coordination Centre.

With no operating reactors and most of the fleet defueled the changes of Magnox using this facility is greatly reduced. They have developed a new simplified system that is more in line with the evolving Company risk profile and tested it to the satisfaction of the ONR.

EDF-Energy, with their fleet of operating reactors will continue to use the CESC.

Removal of the CESC from the Magnox plans is an important step and was a complex process. Magnox and the ONR should be congratulated on the success of this project.

 

I attended the SRP one day meeting on the Implementation of BSS: Ionising Regulations (IRR) and Other Regulations held on 19/1/17 in London. The aim of the Basic Safety Standard Directive in question (Directive 96/29/Euratom – ionizing radiation) is to establish uniform basic safety standards to protect the health of workers and the general public against the dangers of ionising radiation…”.

It was explained that the 2013 Basic Safety Standard has to be implemented in UK law by February 2018 but there were issues relating to registration and dose records that made 1/1/18 a more practical starting date for some clauses of the regulations. Before then there would be a consultation period (which should have started by now), a review of the draft based on the consultation, a final consultation with lawyers and then the draft would be put to the Ministers. The impression was given that the Ministers have a greater ability to change the draft than the consultees. The regulations should be submitted to the EU in autumn and become law in early 2018. It was not explained why so much activity is compressed into the last year of the implementation period given that the BSS was published in 2013 and had been widely consulted on before that.

The graded approach to regulation to be used in IRR17 was described. This balances the requirements of the BSS against the desire for minimal change to UK law and as light a touch as is appropriate. The system of Notification, Registration and Licensing of practices of increasing potential harm will require the user to enter the details of their practices into a web-site database and answer a series of questions to confirm that they have met the requirements of the regulations in terms of risk assessment, contingency planning, training and consultation of an RPA. This system seems very sensible although a number of questions were asked about the number of entries that users of multiple systems and multiple different practices would have to make – one per practice apparently.

The section on REPPIR was very disappointing. It seems possible that the drafting of these regulations and associated guidance are further behind schedule than the IRRs. There was either a reluctance or inability to answer fairly predictable questions from the audience which does not bode well. There are a number of contentious issues with regard to emergency planning regulation in the UK and very little time to adequately consult and get this regulation right. It is important to decommissioning sites, generating sites and new build operators and to the local authorities in whose patches the nuclear sites are found.

There is an interesting story in the USA media (http://triblive.com/local/valleynewsdispatch/11552998-74/dep-site-contamination) which tells us that a community in Pennsylvania has accepted the capping of land contaminated with Radium rather than a complete decontamination. The UK industry and regulators should research the public consultation process that led to this seemingly sensible decision and see if lessons can be learned for our decommissioning efforts.

This is related to the consultation on decommissioning discussed earlier.

 

Found at: http://www.cogentskills.com/media/76258/national-nuclear-skills-strategic-plan.pdf

This document, issued this month (December 2016), shows that a large number of skilled people will be needed if the diverse programme of build (three different designs of LWR, site decommissioning and the naval programme) is to go ahead as planned. It shows a predicted demand of 9000 new skilled workers a year against an expected performance of less than half that.

The document describes policies, risks, actions and benefits of a national plan to manage this situation and ensure that there is a supply of trained people to match the demand.

I’m disappointed not to see “steadily increasing the British contribution to the nuclear projects” included as an aspiration, policy and outcome. If we expect to be building, operating and decommissioning nuclear facilities for the next generation and exporting the skills we should be trying to increase our percentage of the work, particularly the highly skilled work.

It is also not clear the extent to which skills will be defined. I think that it would be useful to have recognised broad and generic skills for people planning to enter the industry but leave flexibility for the final on-the-job training to match them to actual roles. Too much detail and you’ll have trainees taking time and resources to gain a series of skills they will not use at work – it becomes a tick-box exercise moderated by people with a vested interest in utilising their training resources rather than by employers with a job to do.

The Government (BEIS) has issued a consultation document on the simplification of the regulatory regime for nuclear sites in the advanced stages of decommissioning. It proposes removing them from the scope of the Nuclear Installations Act, removing the role of the ONR and leaving the environmental agencies to regulate the final stages of site management.

This should reduce regulatory load and allow optimisation of the radiological clean-up.

https://www.gov.uk/government/publications/discussion-paper-on-the-regulation-of-nuclear-sites-in-the-final-stages-of-decommissioning-and-clean-up

There is a new WHO report on risk communication in paediatric imaging (http://www.who.int/ionizing_radiation/pub_meet/radiation-risks-paediatric-imaging/en/) which I think is a useful contribution.

How should we engage with the public, inform them of the potential risks and benefits of radiation, explain our attempts to minimise radiation dose to our workers and the pubic in normal operation and in accident situations and ask for their informed support for our continued existence?

Maybe you’d write a document modelled on this one.

The medical profession is often accused of being behind the nuclear industry in terms of their attempts to reduce radiation dose to as low as reasonably achievable. This publication could go a long way to reverse that feeling and, in my opinion, represents a level of good practice ahead of the nuclear industry.

The premise of the document is that “Patients and families should be part of risk–benefit discussions about paediatric imaging so they can best understand the information and use it for making informed choices”.

However, the document is clearly not aimed at the public itself. This is evidenced by the opening to the introduction to radiation “Radiation is energy emitted in the form of waves or particles, transmitted through an intervening medium or space. Radiation with enough energy to remove electrons during its interaction with atoms is called “ionizing radiation””, which I suspect is unlikely to encourage anyone without some physics training to read further. What the document does do well is to marshal the arguments and data required for an informed discussion.

The report gives a review of medical procedures and their dose implications and shows how the use of ionising radiations has grown over the last few decades. It provides, with caveats, a table (table 4 of the report) which shows, for a number of procedures, the equivalent number of chest X-rays and the number of days natural background to give the same dose.

It also gives an overview of the health effects of ionising radiation exposure with a quick but useful explanation of deterministic effects, stochastic effects and latency. It states that “Given the current state of knowledge, and despite the uncertainties regarding the risks associated with multiple exposures/cumulative doses, even the low-level of radiation dose used in paediatric diagnostic imaging may result in a small increase in the risk of developing cancer in the future”. It labels this “Lifetime Attributable Risk” (LAR).

This risk is then compared to the Lifetime Baseline Risk (LBR) and graphs are presented that show that females are more susceptible to radiation harm than males and younger people more so than older.

The report suggests a qualitative approach to communication of fatal cancer risk (See below) and a similar one based on the risks of cancer induction. This shows not only the additional risk of cancer but also the total risk.

This then allows different procedures to be discussed using language understood by most people and using a risk assessment that is consistent and justified (See their Table 8, reproduced below).

It has a good section on the optimisation of dose for children during procedures – basically taking account of their smaller size generally allows lower doses to achieve the same resolution.

Section 2 of the report is a review of the principles of radiation protection, how they apply to paediatric medicine and how a radiation safety culture can be encouraged.

Section 3 is about the risk/benefit dialogue. This states that “A recent study that assessed patient knowledge and communication preferences has concluded that there is a substantial gap between patient expectations and current practices for providing information about ionizing radiation medical imaging” and that “A major goal of radiation risk communication in medicine is to ensure that patients, parents and/or caregivers receive the information they need in a way that they can understand”.

The report suggests that while experts see risk as a product of hazard, exposure and susceptibility the public have a more emotional response including fear, anger and outrage and shows how prepared and considered communication at all stages of the referral and exposure process can ease these emotions.
It compares two possible responses to a mother’s concern:

• “The CT that you had two weeks ago has perhaps doubled the risk that your child will develop cancer before age 19.” [0.6% vs 0.3%]; or
• “The CT was an important exam that allowed the physicians to rapidly evaluate and treat your injuries which otherwise could have placed your health and the health of your baby at risk. The risk of adverse outcome is very small and the likelihood of normal development is still nearly the same as it is for any child.” [96.7% vs 96.4%]

And cautions that: “When considering benefits and risks, there is an important risk that is quite often forgotten: the risk of not performing an exam that may result in missing a diagnosis and initiating treatment too late to improve the medical outcome. The potential to improve a patient’s life expectancy due to early diagnosis and treatment must be considered in comparison to the magnitude of the cancer risk and its latency compared to the age of the patient and other comorbidities”.

The report anticipates some of the questions that patients and their carers might ask and provides model answers. It also suggests prepared message maps as a process for collecting and collating evidence.

In summary, this report gives a competent review of the potential health effects of ionising radiation used in paediatric medical imaging and discusses how these doses can be kept as low a reasonably achievable by choosing low-dose options where available and by optimising the imaging conditions taking into account the size of the patient.

It provides the reader with a good review of the risks of ionising radiation and some valuable hints on when and how to communicate this to patient’s carers.

It goes a long way towards enabling an informed discussion leading to shared decisions and understanding about choices made in the care of children.

This new guidance, from the Maritime and Coastguard Agency provides guidelines on pollution response planning for Ports. As is usual for government body advice it seems to be longer than you would have thought necessary (76 pages).

The editing is not great, a footnote on page 7 tells us that new regulation is expected in 2002.

Paragraph 2.18 is interesting to the nuclear industry “Contingency planning for events that have a very low probability of occurrence may be unjustified. The consequences would need to be extremely high to justify contingency planning for events that have a probability of occurring, say, only once every three hundred years or more”. ONR current define “reasonably foreseeable” for nuclear accidents as in the range 0f once in 100,000 to a million years.

The role of the Secretary of State’s Representative (SOSREP) is interesting. According to the National Contingency Plan for Marine Pollution “The SOSREP is empowered to make crucial and often time-critical decisions, without delay and without recourse to higher authority, where such decisions are in the overriding United Kingdom public interest”. I’m not sure there is an equivalent in nuclear emergency planning. The GTA role provided “Authoritative Advice” but has been discontinued. The Gold or Strategic Coordinator merely “coordinates”.  It is interesting to consider whether such a clearly empowered role would be useful.

Approved plans are valid for 5 years compared to 3 for REPPIR. Another penalty paid by the nuclear industry for “nuclear dread”?

 

 

The convention on nuclear safety’s aim is to “legally commit participating States operating land-based nuclear power plants to maintain a high level of safety by setting international benchmarks to which States would subscribe“. The UK’s 7th report to this convention is now available.

At 238 pages long it is not an inviting read but it is, nonetheless, quite interesting and provides a good overview of nuclear safety in the UK including a review of the regulations and the operations of the regulators.

An interesting quote (paragraph 16.23) is “Whilst REPPIR does not prescribe a specific probability to what is reasonably foreseeable, events with a frequency of 1×10(-5) to 10(-6) per year are considered, with any cliff edge effects from events of lesser probability also being considered“. ONR usually reframes from accepting any numerical value for “reasonably foreseeable”. This value puts it below the probability of any events listed in the National Risk Register which may surprise some people.

 

The Government have recently released a policy statement on Military Aid to the Civil Authorities (MACA) (here). This states that the military support to overwhelmed local authorities is provided from “spare capacity” and that “MOD does not generate and maintain forces specifically for this task … because … the requirement is unpredictable in scale, duration and capability requirement” and “experience suggests that requirements can usually be met from spare capacity“.

This is sensible and reasonable and, to date, very successful. During the 2007 summer floods in Gloucestershire floods the military responded to requests to help with over 1000 personnel deployed over an 11 day period. Helicopters and assault boats were used to rescue 193 people and reassure other cut off communities; Chinooks were used to transport a much needed high volume pump and aggregate and personnel filled sandbags, built barriers and distributed drinking water where the water board was struggling. (Pitt Review)

Recommendation 47 of the Pitt Review states that “The Ministry of Defence should identify a small number of trained Armed Forces personnel who can be deployed to advise Gold Commands on logistics during wide-area civil emergencies and, working with the Cabinet Office, identify a suitable mechanism for deployment.”

The government claims that this recommendation has been implemented (here)  with the development of “the existing central response mechanisms” but in  JDP 02 Operations in the UK: The Defence Contribution to Resilience you find that the military support is still described as “provided on an emergency basis and fielded from irreducible spare capacity“.

MACA is a valuable tool in the UK’s emergency response tool box and has been very effective on numerous occasions the fact that it is not obvious that Pitt Recommendation 47 has been fully implemented is a minor concern.